Published 30/01/2020
Unlike Great Britain (England, Scotland and Wales) which is set to take onboard the UKCA mark, Northern Ireland is to remain with the EU CE marking system to ensure that it simplifies the case for Ireland as a whole, and to ensure that Northern Ireland is not disadvantaged by having to apply the UKCA mark. However, Northern Ireland does have some variances to the typical EU CE marking, such as the foreseen UK (NI) mark to be used in certain situations where a UK third party conformity body assessment can be used. Further information can be found on the gov.uk website, which provides guidance on the various trade routes to and from Northern Ireland.
To support our work at Conformance Ltd, we have also developed the following matrix to show all potential trade routes. We would like to note that this is subject to change as the UK government defines and agrees the way forward with the EU and is based on information currently published on the UK governments websites.
| Export of new products (CAB INVOLVED) placed on the market | To | ||||
| GB | NI | EU | Non-EU/EEA | ||
| From | GB | CE mark using EU Notified Body (OK until 1st Jan 2022). UKCA mark using UK Approved Body (can be used from 1st Jan 2021, mandatory from 1st Jan 2022). | Either: CE mark using EU Notified Body, or CE mark + UK(NI) mark using UK Approved Body from 1st Jan 2021. | CE mark using EU Notified Body | Local laws apply |
| NI | Three options: UKCA mark (can be used from 1st Jan 2021) using UK Approved Body, CE mark using EU Notified Body, or CE mark + UK(NI) mark using UK Approved Body from 1st Jan 2021. | Either: CE mark using EU Notified Body, or CE mark + UK(NI) mark using UK Approved Body from 1st Jan 2021. | CE mark using EU Notified Body. | Local laws apply | |
| EU | CE mark using EU Notified Body (OK until 1st Jan 2022). UKCA mark using UK Approved Body (can be used from 1st Jan 2021, mandatory from 1st Jan 2022). | CE mark using EU Notified Body. | CE mark using EU Notified Body. | Local laws apply | |
| Non-EU/EEA | CE mark using EU Notified Body (OK until 1st Jan 2022). UKCA mark using UK Approved Body (can be used from 1st Jan 2021, mandatory from 1st Jan 2022) | Either: CE mark using EU Notified Body, or CE mark + UK(NI) mark using UK Approved Body from 1st Jan 2021. | CE mark using EU Notified Body. | Local laws apply | |
Export of new SELF | To | ||||
| GB | NI | EU | Non-EU/EEA | ||
| From | GB | CE mark (can be used up until 1st Jan 2022). UKCA mark (can be used from 1st Jan 2021, mandatory from 1st Jan 2022) |
CE mark
|
CE mark
| Local laws apply |
| NI | Either, UKCA mark (can be used from 1st Jan 2021), or CE mark | CE mark | CE mark | Local laws apply | |
| EU | CE mark (can be used up until 1st Jan 2022). UKCA mark (can be used from 1st Jan 2021, mandatory from 1st Jan 2022). | CE mark | CE mark | Local laws apply | |
| Non-EU/EEA | CE mark (can be used up until 1st Jan 2022). UKCA mark (can be used from 1st Jan 2021, mandatory from 1st Jan 2022). | CE mark | CE mark | Local laws apply | |
